Finding 1182820 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-25
Audit: 394233
Organization: Lehigh University (PA)

AI Summary

  • Core Issue: The University failed to disburse student credit balances within the required 14-day timeframe, violating federal regulations.
  • Impacted Requirements: Compliance with 34 CFR 668.164(h)(2) regarding timely disbursement of Title IV program funds.
  • Recommended Follow-Up: Implement monitoring procedures for staffing and absences, establish backup protocols, and consider automating disbursement processes to ensure timely compliance.

Finding Text

Finding 2025-002; Student Financial Assistance Cluster – Special Tests and Provisions – Disbursements to and on Behalf of Students – Compliance and Internal Control (Significant Deficiency) Criteria: Federal regulations under 34 CFR 668.164(h)(2) require institutions participating in Title IV programs to disburse a student’s credit balance no later than 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. Condition: The University did not consistently disburse student credit balances within the required 14 day timeframe. Cause: Due to manual nature of the credit reimbursement process, and short-staffing within the department, there were insufficient monitoring controls in place to identify and resolve credit balances approaching the 14 day deadline. Effect: From a non-statistical sample of 22 credit balances, we identified two credit balances of $1,197 that were disbursed beyond the 14 day requirement, resulting in non-compliance with federal regulations. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that management implement procedures to monitor timing of non-workdays, staff absences and scheduled time off that could effect student credit disbursement timing. Management should establish coverage protocols to ensure that the University disburses student credit balances consistently and in a timely manner. Management should designate trained backup personnel and document responsibility for control performance during periods of employee absence. Management should periodically review adherence to these procedures to confirm that credit balance disbursements are performed timely and as designed, regardless of staffing availability. Alternatively, management should consider automating the student credit balance disbursements to reduce reliance on manual processes and/or individual personnel. Views of Responsible Officials: Management acknowledges the errors identified and has taken action to strengthen controls surrounding these processes.

Corrective Action Plan

Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the student was enrolled in the summer term and their summer Pell Grant was not processed until October. As a result, the Title IV credit balance was created well after the end of the summer payment period, outside of our typical refund monitoring cycle for that term. In the second instance, the credit balance was identified within the 14-day requirement. However, the student had not enrolled in direct deposit through the eBill system. Lehigh contacted the student to obtain payment instructions. When no banking information was provided to Lehigh, a paper check had to be issued, which extended the disbursement timeline beyond the 14-day period. While these situations were atypical, we recognize the importance of ensuring timely disbursement regardless of individual circumstances. To strengthen controls, we continue to prioritize Title IV credit balance refunds over refunds resulting from institutional aid or other funding sources to ensure compliance with federal timelines. Although we continue our institutional practice of holding refunds until after the 10th day of class to account for schedule adjustments and enrollment changes, we will begin generating and reviewing credit balance reports earlier in the cycle to allow sufficient processing time. We will implement automated reporting to identify credit balances that occur after the end of an academic period. These reports will be sent to a shared bursar office email account rather than an individual staff member. This will ensure visibility and actionability even during staff absences, turnover, or non-workdays. Responsibility for monitoring and processing Title IV credit balances will be formally documented. Multiple staff members will be trained in the procedures to ensure appropriate backup coverage during employee absences, leave, or staffing transitions. Management will periodically review refund timelines to confirm adherence to procedures and verify that credit balances are disbursed within regulatory timeframes. We believe these corrective actions address the audit recommendation and will ensure timely and consistent processing of Title IV credit balance disbursements regardless of staffing availability.Name of contact person: Jennifer Mertz is the Assistant Vice Provost of Financial Services and Director of Financial Aid. Completion date: All of the control strengthening mechanisms and documentation will be complete by June 30, 2026.

Categories

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring Cash Management Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1182818 2025-002
    Material Weakness Repeat
  • 1182819 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $25.36M
84.063 FEDERAL PELL GRANT PROGRAM $7.97M
12.300 BASIC AND APPLIED SCIENTIFIC RESEARCH $3.73M
84.324 RESEARCH IN SPECIAL EDUCATION $1.82M
47.050 GEOSCIENCES $1.05M
93.173 RESEARCH RELATED TO DEAFNESS AND COMMUNICATION DISORDERS $946,681
81.087 RENEWABLE ENERGY RESEARCH AND DEVELOPMENT $846,581
11.463 HABITAT CONSERVATION $829,590
12.800 AIR FORCE DEFENSE RESEARCH SCIENCES PROGRAM $821,844
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $794,037
84.033 FEDERAL WORK-STUDY PROGRAM $750,000
45.164 PROMOTION OF THE HUMANITIES PUBLIC PROGRAMS $628,576
81.117 ENERGY EFFICIENCY AND RENEWABLE ENERGY INFORMATION DISSEMINATION, OUTREACH, TRAINING AND TECHNICAL ANALYSIS/ASSISTANCE $625,025
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $554,668
47.075 SOCIAL, BEHAVIORAL, AND ECONOMIC SCIENCES $523,247
93.853 EXTRAMURAL RESEARCH PROGRAMS IN THE NEUROSCIENCES AND NEUROLOGICAL DISORDERS $470,033
93.242 MENTAL HEALTH RESEARCH GRANTS $449,299
81.086 CONSERVATION RESEARCH AND DEVELOPMENT $415,666
93.865 CHILD HEALTH AND HUMAN DEVELOPMENT EXTRAMURAL RESEARCH $361,807
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $314,310
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $275,135
12.420 MILITARY MEDICAL RESEARCH AND DEVELOPMENT $271,673
66.034 SURVEYS, STUDIES, RESEARCH, INVESTIGATIONS, DEMONSTRATIONS, AND SPECIAL PURPOSE ACTIVITIES RELATING TO THE CLEAN AIR ACT $220,555
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $216,246
47.074 BIOLOGICAL SCIENCES $205,966
12.910 RESEARCH AND TECHNOLOGY DEVELOPMENT $202,115
93.172 HUMAN GENOME RESEARCH $196,012
11.478 CENTER FOR SPONSORED COASTAL OCEAN RESEARCH COASTAL OCEAN PROGRAM $179,870
93.846 ARTHRITIS, MUSCULOSKELETAL AND SKIN DISEASES RESEARCH $157,111
93.839 BLOOD DISEASES AND RESOURCES RESEARCH $140,308
93.113 ENVIRONMENTAL HEALTH $135,786
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $128,182
19.009 ACADEMIC EXCHANGE PROGRAMS - UNDERGRADUATE PROGRAMS $124,231
93.350 NATIONAL CENTER FOR ADVANCING TRANSLATIONAL SCIENCES $123,955
93.867 VISION RESEARCH $114,257
93.121 ORAL DISEASES AND DISORDERS RESEARCH $112,929
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $107,046
93.273 ALCOHOL RESEARCH PROGRAMS $101,109
93.286 DISCOVERY AND APPLIED RESEARCH FOR TECHNOLOGICAL INNOVATIONS TO IMPROVE HUMAN HEALTH $85,053
93.855 ALLERGY AND INFECTIOUS DISEASES RESEARCH $84,281
84.027 SPECIAL EDUCATION GRANTS TO STATES $82,475
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $73,938
10.309 SPECIALTY CROP RESEARCH INITIATIVE $68,708
14.506 GENERAL RESEARCH AND TECHNOLOGY ACTIVITY $60,358
11.417 SEA GRANT SUPPORT $57,557
20.701 UNIVERSITY TRANSPORTATION CENTERS PROGRAM $53,721
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATION’S HEALTH $53,714
93.393 CANCER CAUSE AND PREVENTION RESEARCH $52,013
47.084 NSF TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $48,721
59.050 PRIME TECHNICAL ASSISTANCE $46,824
84.305 EDUCATION RESEARCH, DEVELOPMENT AND DISSEMINATION $41,727
93.866 AGING RESEARCH $35,735
47.083 INTEGRATIVE ACTIVITIES $33,654
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $33,188
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $33,098
81.135 ADVANCED RESEARCH PROJECTS AGENCY - ENERGY $32,094
93.279 DRUG USE AND ADDICTION RESEARCH PROGRAMS $30,778
93.600 HEAD START $26,639
93.395 CANCER TREATMENT RESEARCH $26,564
11.609 MEASUREMENT AND ENGINEERING RESEARCH AND STANDARDS $25,498
12.431 BASIC SCIENTIFIC RESEARCH $25,234
93.310 TRANS-NIH RESEARCH SUPPORT $24,277
81.089 FOSSIL ENERGY RESEARCH AND DEVELOPMENT $23,657
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $18,871
20.205 HIGHWAY PLANNING AND CONSTRUCTION $17,141
47.041 ENGINEERING $14,680
98.001 USAID FOREIGN ASSISTANCE FOR PROGRAMS OVERSEAS $14,029
10.001 AGRICULTURAL RESEARCH BASIC AND APPLIED RESEARCH $11,601
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $10,514
15.810 NATIONAL COOPERATIVE GEOLOGIC MAPPING $9,635
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $8,360
43.001 SCIENCE $6,353
47.079 OFFICE OF INTERNATIONAL SCIENCE AND ENGINEERING $1,946